https://www.taxtmi.com/caselaws?id=200668 Functional comparability remains the controlling test in transfer pricing, so a company earning substantially different exhibition and event income was excluded from marketing support services comparables, while objections to other proposed exclusions failed. In the software development segment, product or mixed product-service entities were held not functionally comparable to a captive service provider, leading to exclusion of KALS Information Systems Ltd., Thirdware Solutions Ltd. and Acropetal Technologies Ltd., while E-Zest Solutions Ltd., Evoke Technologies Ltd. and E-Infochips Ltd. were retained as comparables. Deduction under section 10A on interest from fixed deposits depended on factual proof of business nexus, so the matter was remitted for verification. en-us Tue, 31 Jan 2017 00:00:00 +0530 Thu, 12 Apr 2018 10:05:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200668 Functional comparability remains the controlling test in transfer pricing, so a company earning substantially different exhibition and event income was excluded from marketing support services comparables, while objections to other proposed exclusions failed. In the software development segment, product or mixed product-service entities were held not functionally comparable to a captive service provider, leading to exclusion of KALS Information Systems Ltd., Thirdware Solutions Ltd. and Acropetal Technologies Ltd., while E-Zest Solutions Ltd., Evoke Technologies Ltd. and E-Infochips Ltd. were retained as comparables. Deduction under section 10A on interest from fixed deposits depended on factual proof of business nexus, so the matter was remitted for verification. Case-Laws Income Tax Tue, 31 Jan 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=200668